Anti-Money Laundering And Counter-Terrorism Financing Policy

Updated on 09 April 2024

Dallas | Sydney | Singapore | Hong Kong |Kuala Lumpur

1.

INTRODUCTION

1.1

Doo Prime combats against any forms of money laundering, terrorism financing or criminal
activities with a strong dedication by strictly complying with the relevant applicable regulatory
regulation.

1.2

Our Money Laundering Reporting Officer(“Officer”) and other compliance executives are
employed to implement the appropriate Anti-Money Laundering and Counter-Terrorism
Financing (“AML and CTF”) policies and procedures. This AML and CTF policy shall coverprocedures and processes:(a)on the client due diligence requirements;(b)

to implement the record-keeping requirements;(c)on the reporting requirements;(d)to inform our officers and employees about money laundering and financing ofterrorism, of the policies, processes, procedures and systems adopted by us to deal
with money laundering and financing of terrorism;(e)

to train our officers and employees to recognise and deal with money laundering andterrorism financing;(f)to vet the officers and employees of Doo Prime to ensure that they are fit and proper
persons to engage in anti-money laundering and counter-terrorism financing related
duties;(g)on the role and responsibility of the Officer;(h)on the establishment of an independent audit function which can test its AML and CTF
processes, procedures and systems; and(i)on the adoption of systems by us in dealing with money laundering and terrorism
financing.

1.3

Doo Prime has established a series of AML procedures and will apply our AML and KnowYour-client (“KYC”) procedures in all transactions. We shall take all reasonable measures toensure that proper protection exists to prevent a contravention of the Applicable Statutes And
Regulations in preventing and mitigating Money Laundering and Terrorism Financing (“MLand TF”) activities. Compliance with the AML and CTF system has always been our utmost
priority to preserve our business reputation in the global financial industry and regulatory
authorities.

1.4

We adopt a risk-based approach in the implementations of our AML and CTF systems andfor the purpose of detecting ML and TF risks. We shall update our AML and CTF systems
and policies at least once annually to take into account new and emerging risks, considering:(a)the nature and level of money laundering and terrorism financing risk that we may
reasonably expect to face in the course of our business;1

Dallas | Sydney | Singapore | Hong Kong |Kuala Lumpur(b)the nature, size and complexity of our business;(c)development of new products and new business practices, including new delivery
mechanisms; and(d)use of new or developing technologies for both new and pre-existing products.

2.

DEFINITIONS AND INTERPRETATIONS

2.1

The following terms shall carry the following meaning:
(a)

(b)

“Applicable Statutes And Regulations” means:(i)statutes, rules or orders of the Relevant Regulatory Authorities;(ii)

statutes, rules or orders of the relevant regulatory authorities in the client’s
jurisdiction;(iii)

the rules of the relevant financial exchange market; and(iv)

all other applicable laws to this policy (and each as amended from time to time
as applicable to this policy).

“Doo Prime” means any one of the following entities, as may be applicable:(i)

Doo Prime Seychelles Limited, Republic of Seychelles. Doo Prime Seychelles
Limited is a licensed securities dealer, authorized and regulated by the
Seychelles Financial Services Authority, and the regulatory number is SD090;(ii)

Doo Prime Mauritius Limited, Republic of Mauritius. Doo Prime Mauritius
Limited is a licensed investment dealer, authorized and regulated by the
Mauritius Financial Services Commission, and the regulatory number is
C119023907;(iii)

Doo Prime Vanuatu Limited, Republic of Vanuatu. Doo Prime Vanuatu Limited
is a licensed financial dealer, authorized and regulated by the Vanuatu
Financial Services Commission, and the regulatory number is 700238.

(c)“Politically exposed person” or “PEP” means an individual who is or has been
entrusted with prominent public functions such as the Head of State, the Prime
Minister, Ministers, senior politicians, senior government officials, judicial or military
officials, senior executive members of state-owned corporations or internationalorganisations and officials of a political part.

(d)“Proceeds of crime” means property derived or realised directly or indirectly from a
serious offence, including:(i)

property into which any property derived or realised directly from the offence islater successively converted or transformed; and2

Dallas | Sydney | Singapore | Hong Kong |Kuala Lumpur(ii)

income, capital or other economic gains derived or realised from that property
since the offence.

If property that is proceeds of crime (the original proceeds) is intermingled with otherproperty from which it cannot readily be separated, that proportion of the whole
represented by the original proceeds is taken to be proceeds of crime.
(e)"Proliferation financing" means the act of providing funds or financial services which
are used, in whole or in part, for the manufacture, acquisition, possession,development, export, trans-shipment, brokering, transport, transfer, stockpiling or use
of nuclear, chemical or biological weapons and their means of delivery and relatedmaterials (including both technologies and dual use goods used for non-legitimate
purposes), in contravention of national laws or, where applicable, international
obligations.

(f)“Relevant Regulatory Authorities” means the relevant regulatory authority which may
be applicable to Doo Prime’s business operation and service providers, including but
not limited to the United States Securities and Exchange Commission, the UnitedStates Financial Industry Regulatory Authority, the United Kingdom Financial Conduct
Authority, the Australian Securities & Investments Commission, the European
Securities and Markets Authority, the Seychelles Financial Services Authority, theMauritius Financial Services Commission, the Vanuatu Financial Services
Commission and etc.

(g)“Source of wealth” refers to the origin of an individual’s entire body of wealth (i.e. total
assets).

(h)“Source of funds” refers to the origin of the particular funds or other assets which are
the subject of the business relationship between an individual and us (e.g. the amounts
being invested, deposited, or wired as part of the business relationship).

(j)“Terrorist financing” or “Terrorism financing” means—(i)the provision or collection, by any means, directly or indirectly, of any property:(aa)with the intention that the property be used; or(ab)knowing that the property will be used, in whole or in part, to commit one
or more terrorist acts (whether or not the property is so used);(ii)

the making available of any property or financial (or related) services, by anymeans, directly or indirectly, to or for the benefit of a person knowing that, or
being reckless as to whether the person is a terrorist or terrorist associate; or(iii)

the collection of property or solicitation of financial (or related) services, by anymeans, directly or indirectly, for the benefit of a person knowing that, or being
reckless as to whether the person is a terrorist or terrorist associate.

3.

MONEY LAUNDERING

3.1

The stages of money laundering are as follows:3

Dallas | Sydney | Singapore | Hong Kong |Kuala Lumpur

3.2

(a)

Placement - disposal of cash proceeds derived from illegal activities;(b)

Layering - separating illicit proceeds from their source by creating complex layers offinancial transactions designed to disguise the source of the money, subvert the audit
trail and provide anonymity; and(c)Integration - creating the impression of apparent legitimacy to criminally derived wealth.
In situations where the layering process succeeds, integration schemes effectively
return the laundered proceeds into the general financial system and the proceeds
appear to be the result of, or connected to, legitimate business activities.

Some of the possible signs of money laundering includes, but is not limited to the following:(a)reluctance by clients to provide information;(b)

incomplete or inconsistent information by clients;(c)irregular money transfers and transactions;(d)unexplained third-party investment;(e)transactions carried by unusually high volume;(f)source of funds from poorly-regulated sources;(g)transactions with no apparent legitimate or economic purpose;(h)transactions which are unnecessarily complex;(i)client’s lifestyle appears in excess of known sources of income;(j)business structure is unnecessarily complicated;(k)use of bank accounts without valid reason;(l)the client appears to be acting as an agent for another entity or individual but is evasive
about the identity of another identity;(m)the client has multiple accounts under a single name or multiple names, with a large
number of inter-account transfers;(n)the client deposit funds followed by a request to withdraw the funds.

4.

CLIENT DUE DILIGENCE (“CDD”)

4.1.

Doo Prime has established a KYC policy to verify the identities of all our clients and to conduct
client due diligence (“CDD”). We perform on-going due diligence process to monitor ourclient’s account, service or relationship with each of our clients to identify, mitigate andmanage the risk it may reasonably face with its client that might involve money laundering,financing of terrorism or other serious offences.
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4.2

4.3

We carry out CDD if a person:(a)opens an account with us;(b)engages our services; or(c)enters into a business relationship with us.

We carry out CDD on:(a)a person conducting a transaction;(b)a person on whose behalf a transaction is being conducted; and(c)a beneficial owner;

if we have reasonable grounds to believe that the person is undertaking a transaction on
behalf of another person. We shall verify whether a person is authorised to undertake thetransaction concerned on behalf of the other person.
4.4

Furthermore, we carry out CDD on the client:(a)before establishing a business relationship with the client;(b)before carrying out for the client or when the client conducts an occasional transactionthat involves an amount equal to or exceeding an aggregate value of USD2,000.00 or
it's equivalent in foreign currency for a large cash transaction or international currencytransfer, whether carried out in a single operation or several operations that appear if
we reasonably think they are linked. In determining whether the transactions are linked,
we will consider the factors in Clause 9.6 against the timeframe within which thetransactions are conducted;(c)when we are requested by Relevant Regulatory Authorities, payment service
providers or service providers to perform appropriate CDD;(d)when we carry out an electronic currency transfer for the client;(e)when we suspect that the client is involved in proceeds of crime, financing of terrorism
or a serious offence regardless of the levels of transaction of 4.4(b) above;(f)when we suspect that the client’s source of funds originated form a third party;(g)when we suspect that the transaction involves proceeds of crime, or may be used forfinancing terrorism or for committing a serious offence; or(h)when we have doubts on the veracity or adequacy of the client identification or
information it had previously obtained,(i)when we are performing our regular CDD routine.
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4.5

Required document list
4.5.1 If the client is an individual, we shall collect the following information:(a)the client's full name;(b)the client's date of birth;(c)the client's residential address;(d)the client's occupation;(e)the client's country(ies) of citizenship;(f)

the client's country(ies) of residence;(g)

the client's occupation or business activities;(h)the nature and purpose of the client's proposed relationship with us, including:(i)the purpose of specific transactions; or(ii)

the expected nature and level of transaction behaviour;(i)authorization of any person purporting to act for or on behalf of the client;(j)

the income or assets available to the client;(k)the client's source of funds including the origin of funds;(l)the client's financial position;(m)the beneficial ownership of the funds used by the client; and(n)the beneficiaries of the transactions being facilitated by us on behalf of the client
including the destination of funds.

4.5.2 If the client is a foreign registered body corporate, we shall collect the following
information:(a)full name of the foreign company;(b)

the country of registration and full registration detail of the client;(c)the full address of the company's principal place of business and registeredaddress;(d)the company structure;(e)name of each company director and secretary;
6Dallas | Sydney | Singapore | Hong Kong |Kuala Lumpur(f)nature of the business activities conducted by the company;(g)name and address of beneficial owners of the company and the control
structure;(h)the country in which the company was formed, incorporated or registered;(i)the provisions regulating the power to bind the client;(j)the authorization of any person purporting to act for or on behalf of the client,and the identity of the persons; and(k)the purpose and intended nature of the business relationship with us.

4.6

We strictly prohibit establishing any business relationship with clients with false, fictitious or
misleading names, and we shall make a record of if any of our client is using a different namefrom which the client is commonly known.

4.7

We will consider on a case by case basis any clients that cannot reasonably be expected to
produce the standard evidence of identity and will seek to agree on the use of otherconfirmations of identity so that clients are not unreasonably denied access to the products
and services. In the event it is reasonably proved that there is doubt on the identification andverification of the beneficial owners, we may carry out CDD on the senior management
officials of the client in accordance with this AML and CTF policy.

5.

CLIENT RISK ASSESSMENT (“CRA”)

5.1

Doo Prime will perform CRA using the risk-based approach. We assess the risk for eachclient taking into account specific products, services, clients, entities, number of transactions,volume of transactions, nature of client relationships, geographic locations, the purpose of
the account or relationship, the level of assets involved, the size of transactions to beundertaken and the regularity or duration of the business relationship.

5.2

We will not accept high-risk clients that are identified as follows:•clients with business that handles a large amount of cash or complex unusually largetransactions, which could not be verified.

•clients with large one-off transactions, or several transactions carried out by the sameaccount within a short time.

•clients based in or conducting business in or through, a high-risk jurisdiction, or ajurisdiction with known higher levels of corruption, organized crime, weapon or drug
production, distribution, stockpiling or acquisition.

•clients falling under the definition of PEP.

•

transactions with the source funds that cannot be verified.

•transactions with no apparent economic or legitimate purpose.

•transactions that might favour anonymity.

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Dallas | Sydney | Singapore | Hong Kong |Kuala Lumpur

5.3

We will conduct a client risk assessment at the initial stage of CDD to determine the extent
of CDD measures and ongoing monitoring measures to be applied. We subsequently take arisk-based approach and conduct ongoing monitoring of business relationships with clientsto manage and mitigate money laundering and terrorism financing risks, and ensure all
related information are updated. The client risk assessment framework shall be proportional
to the nature and size of Doo Prime’s business with clients.

5.4

When we have any reasonable grounds of suspicion, the client will be required to identify andverify the source or destination of the transactions.

5.5

Our steps to conduct the institutional money laundering/terrorism financing risk assessment
include:(a)documenting the risk assessment process which includes the identification andassessment of relevant risks supported by qualitative and quantitative analysis andinformation obtained from relevant internal and external sources;(b)considering all the relevant risk factors before determining the level of overall risk, andthe appropriate level and type of mitigation to be applied;(c)obtaining the approval of senior management on the risk assessment results;(d)having a process by which the risk assessment is kept up-to-date; and(e)having appropriate mechanisms to provide the risk assessment to the Relevant
Regulatory Authorities when required to do so.

6.

SIMPLIFIED DUE DILIGENCE (“SDD”)

6.1

If Doo Prime has determined that ML and TF risks are low, Doo Prime may adopt a simplified
due diligence (“SDD”) approach.

6.2

Clients to whom SDD may be applied are:(a)a financial institution;(b)

an institution that:

(c)

(i)

is incorporated or established in an equivalent jurisdiction;(ii)

carries on a business similar to that carried on by a financial institution;(iii)

is supervised for compliance with those requirements by an authority in thatjurisdiction that performs functions similar to those of any of the regulatory
authorities;

a corporation listed on any stock exchange;8Dallas | Sydney | Singapore | Hong Kong |Kuala Lumpur

(d)

6.3

an investment vehicle where the person responsible for carrying out measures thatare similar to the CDD measures in relation to all the investors of the investment
vehicle is:(i)a financial institution;(ii)

an institution incorporated or established which:•has measures in place to ensure compliance with requirements similar to
those imposed in the Applicable Statutes And Regulations; and•is supervised for compliance with those requirements.

(e)the government or any public body; or(f)the government of an equivalent jurisdiction or a body in an equivalent jurisdiction that
performs functions similar to those of a public body.

In cases of SDD, we will:(a)identify the client and verify the client’s identity;(b)

if a business relationship is to be established and its purpose and intended nature are
not obvious, obtain information on the purpose and intended nature of the business
relationship with us; and(c)

if a person purports to act on behalf of the client,(i)

identify the person and take reasonable measures to verify the person’s identity;
and

(ii)

verify the person’s authority to act on behalf of the client.

7.

ENHANCED DUE DILIGENCE (“EDD”)

7.1

If Doo Prime has determined that ML and TF risks are high, Doo Prime shall adopt anenhanced due diligence (“EDD”) approach and enhanced ongoing monitoring. Approval fromDoo Prime’s senior management will be required before engaging or continuing a business
relationship and/or transaction with high risks clients.

7.2

High-risk situations for which EDD apply includes:(a)client risk factor:(i)business relationship is conducted in unusual circumstances (e.g. significant
unexplained geographic difference between us and the client);(ii)

legal persons or legal arrangements that involve a shell vehicle without a clear
and legitimate commercial purpose;(iii)

companies that have nominee shareholders or shares in bearer form;
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(b)

(c)

7.3

(iv)

cash-intensive business;(v)

the ownership structure of the legal person or legal arrangement appears
unusual or excessively complex given the nature of the legal person’s or legal
arrangement’s business; or(vi)

the client or the beneficial owner of the client is a PEP or foreign PEP.

product, service, transaction or delivery channel risk factors:(i)anonymous transactions (which may involve cash); or(ii)

frequent payments received from unknown or non-associated third parties.

country risk factors. We strictly prohibit all dealings, bank transfers and transactions
with clients from high risk countries, including but not limited to:(i)countries or jurisdictions identified by credible sources, such as mutual
evaluation or detailed assessment reports, as not having effective AML andCTF systems;(ii)

countries identified by the Financial Action Task Force;(iii)

countries or jurisdictions identified by credible sources as having a significant
level of corruption or other criminal activity;(iv)

countries or jurisdictions subject to sanctions, embargoes or similar measures
issued by, for example, the United Nations; or(v)

countries, jurisdictions or geographical areas identified by credible sources asproviding funding or support for terrorist activities, or that have designatedterrorist organisations operation.

Doo Prime reserves the right to obtain information from our independent source for enhanced
due diligence measures. This includes but is not limited to:(a)obtaining additional information on the client (e.g. occupation, volume of assets,
ownership and control structure, client’s or beneficial owner’s reputation, information
available through public databases, internet, etc.), and updating more regularly theidentification data of the client and beneficial owner;(b)obtaining additional information on the intended nature, purpose and background of
the business relationship and transactions;(c)obtaining information on the source of funds or source of wealth of the client;(d)obtaining information on the reasons for intended or performed transactions; and/or(e)requiring the first payment to be carried out through an account in the client’s namewith a bank subject to similar CDD standards.
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7.4

Our EDD entails:
7.4.1

7.4.2

Increasing the quantity of information obtained for client due diligence
purposes:(a)

About the client’s or beneficial owner’s identity, or ownership and control
structure, to be satisfied that the risk associated with the relationship is wellknown. This may include obtaining and assessing information about the client’s
or beneficial owner’s reputation and assessing any negative allegations against
the client or beneficial owner. Examples include: information about family
members and close business partners; information about the client’s orbeneficial owner’s past and present business activities; and adverse media
searches;(b)

About the intended nature of the business relationship, to ascertain whether
that the nature and purpose of the business relationship is legitimate and to help
firms obtain a more complete client risk profile. It includes obtaining informationon:(i)the number, size and frequency of transactions that are likely to passthrough the account to be able to spot deviations that may give rise tosuspicions, requesting evidence where appropriate;(ii)

the reason the client is looking for a specific product or service, inparticular where it is unclear why the client’s needs cannot be met betterin another way, or in a different jurisdiction;(iii)

the destination of funds;(iv)

the nature of the client’s or beneficial owner’s business to understandthe likely nature of the business relationship better.

Increasing the quality of information obtained for client due diligence
purposes to confirm the client’s or beneficial owner’s identity including by:(a)Requiring the first payment to be carried out through an account verifiable inthe client´s name with a bank;(b)

Establishing that the client’s source of wealth and source of funds that are usedin the business relationship are not the proceeds from criminal activity and thatthey are consistent with our knowledge of the client and the nature of thebusiness relationship. The sources of funds or wealth may be verified, among
others, by reference to income tax returns, copies of audited accounts, payslips,
public deeds or independent and credible media reports;(c)Increasing the frequency of reviews, to be satisfied that we continue to be able
to manage the risk associated with the individual business relationship and tohelp identify any transactions that require further review, including by:

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Dallas | Sydney | Singapore | Hong Kong |Kuala Lumpur(i)Increasing the frequency of reviews of the business relationship, toascertain whether the client’s risk profile has changed and whether therisk remains manageable;(ii)

Obtaining the approval of the Officer/nominated officer to commence orcontinue the business relationship to ensure senior management areaware of the risk we are exposed to and can take an informed decision
about the extent to which they are equipped to manage that risk;(iii)

Reviewing the business relationship on a more regular basis to ensure
any changes to the client’s risk profile are identified, assessed and,
where necessary, acted upon;(iv)

Conducting more frequent or in-depth transaction monitoring to identify
any unusual or unexpected transactions that may give rise to suspicion
of money laundering or terrorism financing. This may include
establishing the destination of funds or ascertaining the reason forcertain transactions;(d) The Officer will need to provide approval, or refusal, to proceed with the client
set up process before conducting any business with a client who has been
through the enhanced due diligence process.
7.5

We will apply EDD measures on any situations, clients or transactions that are deemed to behigh risk by us.

7.6

Source of Funds and Source of Wealth7.6.1 Source of wealth refers to the origin of an individual’s entire body of wealth (i.e. total
assets).
7.6.2. Source of funds refers to the origin of the particular funds or other assets which are
the subject of the business relationship between an individual and us (e.g. the amounts
being invested, deposited, or wired as part of the business relationship).

7.7

How Source of Funds and Source of Wealth measures are incorporated into our EDD
Process
7.7.1 Source of wealth will usually indicate the size of wealth the client would be expected
to have, and a picture of how the individual acquired such wealth. Although we may
not have specific information about assets not deposited with or processed by it, it
may be possible to gather general information from the individual, commercial
databases or other open sources.
7.7.2 Source of funds information should not simply be limited to knowing from which thefunds may have been transferred, but also the activity that generates the funds. The
information obtained should be substantive and establish a provenance or reason for
the funds having been acquired.

7.8

It is Doo Prime’s policy not to accept any funding from any third party, but in the event suchexceptional circumstances occur, we shall conduct EDD to identify and verify its ultimate
beneficial owner including legal person, partnership, trust and other legal arrangements.
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8.

VERIFICATION

8.1

We shall verify and screen the client’s information above through our client service and risk
management department before we establish relationship with them. Our scope of CDD
includes, but is not limited to our retail clients, business partners, the board members,
shareholders and ultimate beneficial owner. We carry out the following CDD measures:(a)identify, verify and screen the client’s identity and information via an independent
screening system;(b)where there is a beneficial owner in relation to the client, identifying and taking
reasonable measures to verify the beneficial owner’s identity so that we are satisfied
that we know who the beneficial owner is, including in the case where the client is alegal person or trust, measures to enable us to understand the ownership and control
structure of the legal person or trust;(c)obtaining information on the purpose and intended nature of the business relationship(if any) established with us unless the purpose and intended nature are obvious; and(d)if a person purports to act on behalf of the client:

(e)

(i)

identifying the person and taking reasonable measures to verify the person’s
identity using documents, data or information provided by reliable andindependent source; and(ii)

verifying the person’s authority to act on behalf of the client;

if we deem the identity verification insufficient or if we require additional details relevantto the transaction performed by the client, we reserve the right to request additional
details from the client (including but not limited to bank statement, proof of bankaccount, electronic wallet or electronic currency statement) and reserve our right notto establish a business partnership or proceed with any further transaction. If the client
either refuses to provide the required information, or provide false/misleading
information, we may freeze the client account, restrict trading or account activity,
terminate the business partnership and/or report to the regulatory authority. Uponsatisfactory verification of the client’s identity and the transaction details, all restrictions
applied on the account shall be lifted.

8.2

In the identity verification process, we will request a copy of the original and a coloured
scanned copy of the identification documents; we may also request more than one identity
documents for cross-verification if we deem necessary.

8.3

When electronic verification is used or a client has not been physically present for
identification purposes, we will carry out an additional verification check to manage the riskof impersonation fraud. This check may take the form of:(a)requiring the first payment to be carried out through an account in the client’s namewith a regulated credit institution;13

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8.4

(b)

telephone contact with the client on a home or business number that has been verified,
before opening the account;(c)communicating with the client at the address that has been verified;(d)requiring copy documents to be certified by an appropriate person.

If we are unable to carry out the prescribed identification process on a person, we:(a)shall not open an account for the person;(b)shall not enter into a business relationship with the person; and(c)

if a business relationship already exists with the person, we shall terminate the existing
business relationship.

9.

REPORT

9.1

If satisfactory evidence of the identity or verification of a person is not produced to or obtainedby us within 14 working days (2 working days if Clause 4.4(d) and (e) arise), we shall submit
a suspicious activity report to the Relevant Regulatory Authorities. We shall not proceed any
further with the transaction unless directed to do so by the Relevant Regulatory Authorities.

9.2

In the event we suspect on reasonable grounds that the client is not the person that he or
she claims to be, we shall take one or more of the actions below within 3 working days
commencing after the day on which the circumstance comes into existence:

9.3

9.4

(i)

collect the necessary client identification information in respect of the client; or(ii)verify, from a reliable and independent source, certain client information that has beenobtained in respect of the client; to ensure it is reasonably satisfied that the client is
the person that he or she claims to be.

When determining and putting in place appropriate risk-based systems and controls, we shallconsider the nature, size and complexity of the client’s business and type of ML and TF risks
that we might reasonably face, including but not limited to the following factors:(a)client types, including PEPs;(b)the types of designated services provided;(c)method by which we deliver designated services, including any development of new
products, business practices and use of new or developing technologies;(d)the foreign jurisdictions with which we deal, including high risk jurisdictions as
identified by Financial Action Task Force.

If any of the following events occurs:(a)suspicious transaction;
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Dallas | Sydney | Singapore | Hong Kong |Kuala Lumpur(b)suspicious activity;(c)transaction conducted by money laundering entities;(d)transaction involving terrorist property;(e)transaction with no legitimate purpose;(f)

our supervisory body or auditor has reasonable grounds to suspect that a transaction
or an attempted transaction or information that it has in its possession involves
proceeds of crime or is related to the financing of terrorism; or(g)any transaction described in Clause 3.2;
the transaction should be suspended and should not proceed without the authorizationof the Officer. Our frontline staff shall report any suspicious transaction or activity
without delay to the Officer, who will then make a suspicious activity or suspicioustransaction report to the Relevant Regulatory Authorities in 2 working days if required.

9.5

9.6

If suspicious signals of money laundering are identified, the transaction should be suspended
and should not proceed without the authorization of the Officer. After making appropriate
investigations, the Officer will report the matter to the Relevant Regulatory Authorities if we
believe there is any potential serious ML and TF risks. In the event we deem a person
conducts 2 or more transactions with the intention to avoid the amount threshold as describedin Clause 4.4(b), we shall submit a suspicious transaction report to the Relevant Regulatory
Authorities. We shall consider the following factors before submitting our report:(a)the manner and form in which the transactions were conducted;(b)

the amount of the currency involved in each transaction;(c)the aggregate amount of the currency involved in the transactions;(d)the period over which the transactions occurred;(e)the interval of time between the transactions;(f)the locations at which the transactions were initiated or conducted;(g)

any explanation made by the person concerned as to the manner or form in which thetransactions were conducted.

Procedure of handling suspicious activity report and suspicious transaction report
9.6.1 After making appropriate investigations, the Officer will consider, if appropriate,
reporting the matter to the regulatory authority. All records to the Officer and therelevant authorities, shall be kept by the Officer for a term of no less than 7 years after
the matter has been closed by the regulatory authority. The suspicious activity reportor suspicious transaction report shall include:15

Dallas | Sydney | Singapore | Hong Kong |Kuala Lumpur(a)personal particulars and contact details of the individuals or entities involved in
the suspicious activity or transaction;(b)

details of the suspicious activity or transaction;(c)the suspicious activity or transaction indicators observed; and(d)any explanation provided by the subject of the suspicious activity report orsuspicious transaction report when questioned about the transaction or activity.

9.6.2 The filing of a suspicious activity report or suspicious transaction report to the Relevant
Regulatory Authorities provides us a statutory defence to the offence of ML and TF in
respect of the acts disclosed in the report, provided that:(a)the suspicious activity report or suspicious transaction report is made before
we undertake the disclosed acts and the acts or transactions are undertakenwith the consent of the Relevant Regulatory Authorities; or(b)

the suspicious activity report or suspicious transaction report is made after wehave performed the disclosed acts or transactions and the report is made on
our initiative and as soon as it is reasonable for us to do so.

9.7

All notifications made will be handled with strict confidentiality. However, please note that
there may be circumstances in which we are required to reveal an individual’s identity, forexample where we are compelled to do so by law and therefore anonymity cannot be
guaranteed.

9.8

We are aware that it is an offence for a person, knowing or suspecting that a disclosure has
been made to the Relevant Regulatory Authorities, if he/she discloses to any other person
any matter which is likely to prejudice any investigation which might be conducted following
the disclosure (commonly referred to as “tipping-off”). The client’s awareness of a possible
suspicious activity report or suspicious transaction report or investigation could prejudice
future efforts to investigate the suspected ML and TF operation. Therefore, if we form asuspicion that transactions related to ML and TF, we will take into account the risk of tippingoff when performing the CDD process. We shall ensure that our employees are aware of andsensitive to these issues when conducting CDD.

9.9

We shall not disclose any information to any other person:(a)that we, or our supervisory body or auditor or a person has formed a suspicion in
relation to a transaction or an attempted transaction, or an activity or attempted activity;or(b)that a report under Applicable Statutes And Regulations is made to Relevant
Regulatory Authorities; or(c)that information under the Applicable Statutes And Regulations is given to Relevant
Regulatory Authorities; or(d)any other information from which a person to whom the information is disclosed may
reasonably be expected to infer any circumstances in paragraph (a)-(c).
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9.10

9.11

Clause 9.9 does not apply to a disclosure made to:(a)an officer, employee or agent of a Doo Prime who has made or is required to make areport or provide information under this Applicable Statutes And Regulations for any
purpose connected with the performance of that our duties; or(b)a lawyer for the purpose of obtaining legal advice or representation in relation to thedisclosure; or(c)the supervisor of Doo Prime; or(d)a law enforcement agency or any other person assisting the Relevant Regulatory
Authorities under this Applicable Statutes And Regulations.

The responsibilities of our Officer include, but is not limited to the following:(a)

Review all internal reports of suspicious transactions and exception reports and, in thelight of all available information, determine whether or not it is necessary to file a
suspicious activity report or suspicious transaction report with the Relevant Regulatory
Authorities;(b)

Maintain all records relating to such internal reviews;(c)Guide staff on how to avoid “tipping-off” if any suspicious activity report or suspicioustransaction report is filed;(d)Applicable Statutes And Regulations as the main point of contact with the Relevant
Regulatory Authorities, law enforcement agencies, and any other competentauthorities in relation to ML and TF prevention and detection, investigation orcompliance.

10.

ONGOING CDD AND TRANSACTION MONITORING

10.1

We shall conduct ongoing monitoring through ongoing CDD and transaction monitoring toensure compliance with the AML and CTF Systems. We shall review the existing CDD
records upon any trigger events and maintain adequate systems to monitor transactions inaccordance with the risk-based approach adopted. The extent of monitoring shall be
proportional to the ML and TF risk profile of a client.

10.2

Ongoing CDD
10.2.1 We continuously monitor the activity of our clients by:(a)reviewing from time to time documents, data and information relating to theclient that have been obtained to comply with CDD requirements to ensure thatthey are up-to-date and relevant;(b)conducting appropriate scrutiny of transactions carried out for the client toensure that they are consistent with our knowledge of the client and the clients’business, risk profile and source of funds; and17

Dallas | Sydney | Singapore | Hong Kong |Kuala Lumpur(c)identifying transactions that are complex, unusually large in amount or of an
unusual pattern or that have no apparent economic or lawful purpose and which
may indicate ML and TF.

10.2.2 All clients that present:(a)high ML and TF risks should be subject to a review every 6 months;(b)medium ML and TF risks should be subject to a review once annually;(c)

low ML and TF risks should be subject to a review once every 2 years;

or more frequent reviews if deemed necessary by us, to ensure the CDD information
retained is consistent with our knowledge of the client, the client’s business, source offunds and risk profile.
10.2.3 All clients, who have been classed as high risk, will undergo a complete review. This
will entail establishing the following:

10.3

•

Re-confirmation of address•

Re-confirmation of corporate structure (if applicable)•

Re-confirmation of Source of Funds and Wealth•

Screening for adverse news•

Complete review of transaction profile, including new products requested

Transaction monitoring
10.3.1 We maintain adequate systems to monitor and review all transactions performed
based on a risk-based approach, and we shall check and review whether thetransactions are normal based on the following factors:(a)the size and complexity of its business;(b)

the ML and TF risks arising from its business;(c)the nature of its systems and controls;(d)the monitoring procedures that already exist to satisfy other business needs;
and

(e)

the nature of the products and services provided (which includes the means ofdelivery or communication).

10.3.2 We regularly review the adequacy and effectiveness of its transaction monitoring
systems and processes, including parameters and thresholds adopted. The
parameters and thresholds adopted include the following factors:
18

Dallas | Sydney | Singapore | Hong Kong |Kuala Lumpur(a)the nature and type of transactions (e.g. abnormal size or frequency);(b)

the nature of a series of transactions (e.g. structuring a single transaction into
several cash deposits);(c)

the counterparties of transactions;(d)the geographical origin/destination of a payment or receipt;(e)the client’s normal account activity or turnover;(f)

the client’s behaviour - sudden and/or significant changes in transaction activity
by value, volume or nature, such as change in beneficiary or destination;(g)client’s linked relationships – identifying common beneficiaries and remittersamongst apparently unconnected accounts or clients.

11.

RECORD KEEPING

11.1

Records of all original and copy of identity verification documents, transaction records, CDD
information, ML and TF reports made to Officer, all documents submitted in relation tosuspicious activity report, suspicious transaction report, staff handling the suspicioustransaction report, results of the suspicious transaction report and other documents
necessary under the Officer will be compiled and organized with confidentiality for at least 7
years after the end of the business relationship with clients.

11.2

The record-keeping requirements in respect of each client are as follows:
(a)

(b)

11.3

We must keep the original or a copy of:(i)the documents, and a record of the data and information obtained in the courseof identifying and verifying the identity of the client; beneficial owner of the client;and the person who purports to act on behalf of the client; and(ii)

the files relating to the client’s business relationship and businesscorrespondence with the client and any beneficial owner of the client; andThe documents and records mentioned in sub-paragraph (a) above must be kept
throughout the continuance of the business relationship with the client and for at least
seven years beginning on the date on which the business relationship ends.

The record keeping requirements in respect of each transaction are as follows:(a)

We will keep the original or a copy of the documents, and a record of the data andinformation obtained in connection with the transaction, including but not limited to thefollowing:(i)nature of the transaction;(ii)

the amount of the transaction and the currency in which it was denominated;
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(b)

(iii)

the date on which the transaction was conducted;(iv)

the name, address and occupation, business or principal activity, as the caserequires, of each person:(aa)

conducting the transaction; and(ab)for whom, or for whose ultimate benefit, the transaction is being
conducted, if we have reasonable grounds to believe that the person isundertaking the transaction on behalf of any other person;(v)

the type and identifying number of any accounts/services with us that wereinvolved in the transaction;(vi)

if the transaction involves a negotiable instrument other than currency:(aa)

the drawer of the instrument;(bb)

the name of the institution on which it is drawn;(cc)

the name of the payee (if any);(dd)

the amount and date of the instrument; and(ee)the number (if any) of the instrument and details of any endorsements
appearing on the instrument;(vii)

the name and address of Doo Prime, and of each officer, employee or agent of
Doo Prime who prepared the relevant record or a part of the record;(viii)

any other information relating to that transaction.

Records required to be kept under subparagraph (a) must be kept for at least sevenyears beginning on the date on which the transaction is completed, regardless ofwhether the business relationship ends during the period.

12.

AML AND CTF SCREENING PROCESS

12.1

Clients will be screened against lists of sanctions, politically exposed persons, regulatory
enforcement, law enforcement, money laundering, terrorism financing, adverse media
reports provided by Refinitiv Limited’s World-Check One screening system. Clients will be
added to World-Check One’s ongoing monitoring list whereby their details will be
automatically searched by the system every 12 hours. We will receive an alert whenever
there are any positive matches.

12.2

We screen:(a)clients and any beneficial owners of the clients against the current database at theestablishment of the relationship;20

Dallas | Sydney | Singapore | Hong Kong |Kuala Lumpur(b)clients and any beneficial owners of the clients against all new and any updated
designations to the database as soon as practicable; and(c)all relevant parties in a cross-border wire transfer against the current database before
executing the transfer.

12.3

In case of any suspicions of terrorism financing, proliferation financing and sanctions
violations, we will submit a suspicious activity or suspicious transaction report to the Relevant
Regulatory Authorities. We will report any asset frozen or actions taken in compliance withthe financial sanctions requirements by way of filing a suspicious activity report or suspicioustransaction report to the Relevant Regulatory Authorities.

13.

AML AND CTF AUDIT FUNCTION

13.1

The Officer and our compliance department conduct an internal audit on our AML and CTF
policy annually to ensure our AML and CTF policy are updated. We are aware of our statutory
liability to comply with the Applicable Statutes And Regulations and we shall update andreview our AML and CTF policy at least once annually.

13.2

We will regularly identify and assess ML and TF risks that may arise in relation to:(a)the nature and level of money laundering and terrorism financing risk that we may
reasonably expect to face in the course of its business;(b)

the nature, size and complexity of our business;(c)development of new products and new business practices, including new delivery
mechanisms; and(d)use of new or developing technologies for both new and pre-existing products.

14.

TRAINING PROGRAMME

14.1

All relevant staff in Doo Prime will be provided with relevant policy and knowledge training
provided in this AML and CTF Policy. In addition, all relevant staff in Doo Prime will be briefed
about their job descriptions and will be trained on their responsibilities concerning money
laundering and financing of terrorism transactions. They will be guided on how to identify anddeal with transactions that possibly involve money laundering and financing of terrorism.

14.2

Scope of training
14.2.1 Staff will be made aware of:(a)our statutory obligations and their statutory obligations and the possible
consequences for failure to report suspicious transactions under the Applicable
Statutes And Regulations and the Regulation;(b)

any other statutory and regulatory obligations that concern the us under the
Applicable Statutes And Regulations and the Regulation, and the possible
consequences of breaches of these obligations;21

Dallas | Sydney | Singapore | Hong Kong |Kuala Lumpur(c)our policies and procedures relating to AML and CTF, including suspicious
activity and transaction identification and reporting;(d)any new and emerging techniques, methods and trends in ML and TF to theextent that such information is needed by the staff to carry out their respectiveroles concerning AML and CTF;(e)escalation procedures, i.e. what to do once a ML and TF risk is identified;(f)what the employee’s role is in our compliance’s efforts and how to perform them;(g)record keeping and record retention policy; and(h)disciplinary consequences (civil and criminal) for non-compliance with theApplicable Statutes And Regulations.

14.2.2 Focused training for appropriate staff or groups of staff will enable Doo Prime andsenior management to implement their AML and CTF systems effectively. The
following areas of training may be appropriate for certain groups of staff:
(a)

(b)

(c)

All new staff (irrespective of seniority)(i)an introduction to the background of ML and TF and the importance of
AML and CTF to us; and(ii)

the need and obligation to identify and report suspicious transactions to
the Officer, and the offence of “tipping-off”.

Front-line staff (i.e. staff dealing with clients directly)(i)the importance of their roles in the company’s AML and CTF strategy
being the first point of contact with potential money launderers andpersons involved in TF;(ii)

the company’s policies and procedures in relation to CDD and recordkeeping requirements relevant to their job responsibilities;(iii)

guidance or tips for identifying unusual activities in different
circumstances that may give rise to suspicion; and(iv)

the relevant policies and procedures for reporting unusual activities,
including the line of reporting and the circumstances where extra
vigilance might be required.

Back-office staff(i)appropriate training on client verification and the relevant processing
procedures; and22

Dallas | Sydney | Singapore | Hong Kong |Kuala Lumpur

(ii)
(d)

(e)

14.3

ways to recognise unusual activities including abnormal settlements,
payments or delivery instructions.

Managerial staff (including internal audit staff)(i)higher-level training covering all aspects of AML and CTF regime;(ii)

specific training in the AML and CTF requirements applicable to us; and(iii)

specific training in relation to their responsibilities for supervising or
managing staff, auditing the system and performing random checks aswell as the reporting of suspicious transactions to the Relevant
Regulatory Authorities.

Officer(i)

specific training in relation to the Officer’s responsibilities for assessing
suspicious transaction reports submitted to them and reporting of
suspicious transactions to the Relevant Regulatory Authorities;(iii)

training to keep abreast of AML and CTF requirements/developments
generally;(iv)

receive reports of suspicious activity from firm personnel; and(iv)

coordinate required AML reviews/meetings with appropriate staff.

We will monitor the effectiveness of the training. This may be achieved by:(a)testing staff’s understanding of our policies and procedures to combat ML and TF, theunderstanding of their statutory and regulatory obligations, and also their ability torecognise suspicious transactions;(b)monitoring the compliance of staff with our AML and CTF systems as well as thequality and quantity of internal reports so that further training needs may be identified
and appropriate action can be taken; and(c)monitoring attendance and following up with staff who miss such training without
reasonable cause.

14.4

We conduct AML training, workshops and assessments on all related staff members at least
once annually.

14.5

We shall observe and record our employees who have been adequately trained, when they
are trained or last trained, and thereafter provide additional, necessary and adequate training
to them.

15.

LANGUAGE AND AMENDMENTS

15.1

The official language of this AML and CTF policy shall be English. Doo Prime may provide
this AML and CTF policy in other languages for information purposes only and in the eventof any inconsistency or discrepancy between the English version of this AML and CTF policy
and any other language version, the English version shall prevail.
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Dallas | Sydney | Singapore | Hong Kong |Kuala Lumpur

15.2

The client acknowledges that Doo Prime reserves the right to amend or update this AML andCTF policy at any time without prior notice to the client. The amendments to the AML andCTF policy shall become effective immediately and shall be legally binding on the client upon
publishing of the AML and CTF policy on Doo Prime’s website. The client undertakes toregularly review this AML and CTF policy on the Doo Prime’s website.
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